State v. Porter
In State v. Porter, 133 Wn.2d 177, 942 P.2d 974 (1997), the defendant pleaded guilty to three counts of delivery of controlled substances.
Two of those counts arose from a single incident in which the defendant sold two different controlled substances, almost simultaneously, to an undercover officer.
Nevertheless, the Court held that those two counts encompassed the "same criminal conduct" because the defendant's "criminal intent could not be segregated into distinct present and future intents to commit criminal activity." Porter, 133 Wn.2d at 184.